Bankruptcy Courts Lack Jurisdiction to Enjoin Independent Tort Claims against Nondebtors Future Claimants Not Bound Absent Adequate Representation

C.R. “Chip” Bowles, Jr. and Jacob C. Cohn, Bankruptcy Courts Lack Jurisdiction to Enjoin Independent Tort Claims against Nondebtors, XXIX ABI Journal 5, 34-35, 55, June 2010